Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024-004: 10. 761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and Training - Material Weakness Compliance Requirement: Subrecipient Monitoring Criteria: Per Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Subpart D, section 200.332, the non-Federal entity must determine the subrecipient is not excluded or debarred or otherwise excluded from receiving Federal funds, as well as develop written subrecipient monitoring policies and procedures. Condition: During our testing of internal controls over compliance related to subrecipient monitoring, we identified EWB-USA did not have written subrecipient monitoring policies or procedures in place, nor determine that the subrecipient was not suspended or debarred or otherwise excluded from receiving Federal funds. Additionally, EWB-USA did not obtain a copy of the subrecipient's Uniform Guidance compliance audit. Questioned Costs: None. Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable federal requirements. Effect: EWB-USA was not in compliance with the subrecipient monitoring provisions as prescribed in the Uniform Guidance. Recommendation: We recommend that EWB-USA adopt formal, written subrecipient monitoring policies and procedures the comply with the Uniform Guidance. Response: 1. Develop a policy for subrecipient monitoring, and implement procedures to oversee the programmatic and financial activities of subrecipients and ensure compliance with regulations. 2. Develop a standardized checklist to guide the monitoring of subrecipients. 3. Provide training to relevant staff on the new procedures for subrecipient monitoring and the importance of compliance with federal regulations.
Finding 2024-004: 10. 761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and Training - Material Weakness Compliance Requirement: Subrecipient Monitoring Criteria: Per Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Subpart D, section 200.332, the non-Federal entity must determine the subrecipient is not excluded or debarred or otherwise excluded from receiving Federal funds, as well as develop written subrecipient monitoring policies and procedures. Condition: During our testing of internal controls over compliance related to subrecipient monitoring, we identified EWB-USA did not have written subrecipient monitoring policies or procedures in place, nor determine that the subrecipient was not suspended or debarred or otherwise excluded from receiving Federal funds. Additionally, EWB-USA did not obtain a copy of the subrecipient's Uniform Guidance compliance audit. Questioned Costs: None. Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable federal requirements. Effect: EWB-USA was not in compliance with the subrecipient monitoring provisions as prescribed in the Uniform Guidance. Recommendation: We recommend that EWB-USA adopt formal, written subrecipient monitoring policies and procedures the comply with the Uniform Guidance. Response: 1. Develop a policy for subrecipient monitoring, and implement procedures to oversee the programmatic and financial activities of subrecipients and ensure compliance with regulations. 2. Develop a standardized checklist to guide the monitoring of subrecipients. 3. Provide training to relevant staff on the new procedures for subrecipient monitoring and the importance of compliance with federal regulations.
2024-001: Internal Control over Compliance with Subrecipient Monitoring and Noncompliance with Subrecipient Monitoring U.S. Department of Health and Human Services; Passed through the State of Tennessee Department of Health: ALN #93.558 Temporary Assistance for Needy Families Federal Award Identification: 68080 Grant Year: 10/1/2020-9/30/2024 Criteria: 2 CFR section 200.332(d) states: Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200-521. Condition and context: The Organization typically requests and reviews subrecipient financial statement audits on an annual basis with annual renewals of contracts. The Temporary Assistance for Needy Families Grant has a three-year grant period. Since subrecipients weren't required to have annual renewals, the Organization did not request or review the annual financial statement audits of subrecipients of this grant. Therefore, the Organization did not comply with the monitoring required by 2CFR section 200.332(d). Cause: The Organization’s internal controls over subrecipient monitoring were not sufficiently designed and implemented to ensure that applicable audits from subrecipients were obtained and reviewed annually. Effect or potential effect: Procedures required by 2 CFR section 200.332(d) related to reviewing financial reports of the subrecipient and following-up on deficiencies pertaining to the Federal award could not completed. The Uniform Guidance audit could have noted findings related to compliance with the spending of the federal assistance that would have been unknown to the Organization. Recommendation: We recommend that the Organization track all subrecipient with federal assistance and establish a process to ensure the financial statement and Uniform Guidance audits are obtained timely and monitoring procedures required by 2 CFR section 200.332(d) are completed. Views of responsible officials: Management acknowledge this finding and will address remediation in the accompanying corrective action plan in Appendix A
Federal Agency: United States Department of Commerce Federal Program Name: Office for Coastal Management Assistance Listing Number: 11.473 Federal Award Identification Year: 2020 Pass-Through Agency: National Fish and Wildlife Grant Agreement Award Period: 9/1/20-08/02/24 Compliance Requirement Affected: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted. Context: A nonstatistical sample of 2 out of 4 subrecipients were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over CFSC’s subrecipients. Effect: CFSC did not perform the following, which increases the risk of noncompliance: -Required risk assessments for the subrecipients, -Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any. Cause: CFSC’s procedures did not consistently ensure that the required risk assessments were performed. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above. Management’s Views: See separate corrective action plan.
Criteria: Per 2 CFR 200.332, Mesa County is responsible for informing subrecipients of the Federal award identifiers including but not limited to award date, period of performance and Federal awarding agency and Assistance Listing Number and title. Mesa County is required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. In addition, the County should also verify that the subrecipient is audited as required by Subpart F - Audit Requirement under the Uniform Guidance. The monitoring policy should include an initial valuation of risk of noncompliance to determine the appropriate level of monitoring required related to the subaward as well as appropriate awarding documentation. Condition: During our testing, we evaluated the procedures for evaluating subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. We noted the following: • For two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient’s risk of noncompliance was not documented. Cause: The County did not adhere to their established policies and procedures relating to risk assessment when a subrecipient contract is awarded. Effect: The County’s policies were not consistently followed requiring compliance with the Subrecipient monitoring requirements in 2 CFR 200.332. Additionally, the County’s control policies were not consistently followed. Questioned Costs: None to report. Context/Sampling: The population of two (2) subrecipients were selected for subrecipient monitoring testing for the direct award from the US Department of Treasury. The total population across the program, including sub-awards from the State of Colorado was 2 subrecipients. Repeat Finding from Prior Years: Yes. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Agree
Significant deficiency in internal controls over subrecipient monitoring. • Program Title: Substance Abuse Block Grants • Assistance Listing Number: 93.959 • Federal award identification number: B08TI085843 • Federal Agency: Department of Health and Human Services • Pass-through Entity: Washington State Health Care Authority Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.332 requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward. Condition/Context Washington Association of Sheriffs & Police Chiefs (the Association) passes substantially all federal funding through to subrecipients. During testing it was identified that, although the Association satisfied all ongoing monitoring requirements, on the coversheet of all subrecipient contracts in place during the year, a box indicating that the third party was not a subrecipient was incorrectly checked. This error by default incorrectly communicated to their subrecipients that they were contractors. Cause Washington Association of Sheriffs & Police Chiefs’ internal controls related to the review of subrecipient contracts were not functioning properly causing the pervasive error to be overlooked. Effect or potential effect Subrecipients were not clearly communicated their roles. Questioned costs N/A Repeat audit finding No Recommendation We recommend that Washington Association of Sheriffs & Police Chiefs ensure there is a proper understanding of the nature of a subrecipient vs a contractor, and that they ensure that this determination is being reviewed, and clearly communicated in underlying agreements, as part of their internal control processes Views of responsible officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report
2024-001 Significant Deficiency in Internal Controls over Compliance and Compliance, Other Matter – Procurement (suspension and debarment) Agency: U.S. Department of the Interior Program(s) and Federal Award Listing Number(s): Partners for Fish and Wildlife ALN: 15.631 FAIN: FA22AC02756, FA23AC02476 New or Repeat: New Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Per 2 CFR Part 180, as referenced in 2 CFR Part 1400, for any contract expected to total $25,000 or more, a recipient of federal funds must confirm that the contractor is not suspended or debarred from receiving federal funds. Per 2 CFR 200.332, a pass-through entity must verify that the subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds in accordance with 2 CFR 180.300. Condition: SAWC was not able to provide supporting documentation indicating that it had verified that contractors and subrecipients were not suspended or debarred prior to contracting with, or making a subaward to, the entities. Cause: Internal controls were designed, but not sufficiently implemented to ensure that documentation of the check for suspension and debarment was retained. Effect: SAWC could have contracted with, or made a subaward to, an entity that was suspended or debarred. Context: We tested 100% of the procurement population. For three of the three contractors/subrecipients tested, we were not able to verify that SAWC confirmed the contractor/subrecipient was not suspended or debarred prior to entering into the transaction. Questioned costs: There are no questioned costs associated with this finding. Recommendation: We recommend SAWC consider either collecting a certification regarding suspension and debarment from contractors/subrecipients or adding a suspension and debarment clause or condition to contracts and subawards. View of responsible officials: Management concurs with this finding, see corrective action plan.
2024-001 Significant Deficiency in Internal Controls over Compliance and Compliance, Other Matter – Procurement (suspension and debarment) Agency: U.S. Department of the Interior Program(s) and Federal Award Listing Number(s): Partners for Fish and Wildlife ALN: 15.631 FAIN: FA22AC02756, FA23AC02476 New or Repeat: New Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Per 2 CFR Part 180, as referenced in 2 CFR Part 1400, for any contract expected to total $25,000 or more, a recipient of federal funds must confirm that the contractor is not suspended or debarred from receiving federal funds. Per 2 CFR 200.332, a pass-through entity must verify that the subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds in accordance with 2 CFR 180.300. Condition: SAWC was not able to provide supporting documentation indicating that it had verified that contractors and subrecipients were not suspended or debarred prior to contracting with, or making a subaward to, the entities. Cause: Internal controls were designed, but not sufficiently implemented to ensure that documentation of the check for suspension and debarment was retained. Effect: SAWC could have contracted with, or made a subaward to, an entity that was suspended or debarred. Context: We tested 100% of the procurement population. For three of the three contractors/subrecipients tested, we were not able to verify that SAWC confirmed the contractor/subrecipient was not suspended or debarred prior to entering into the transaction. Questioned costs: There are no questioned costs associated with this finding. Recommendation: We recommend SAWC consider either collecting a certification regarding suspension and debarment from contractors/subrecipients or adding a suspension and debarment clause or condition to contracts and subawards. View of responsible officials: Management concurs with this finding, see corrective action plan.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
2024-001 Research and Development Cluster – Education Innovation and Research (formerly Investing in Innovation (i3) Fund – Validation Grants) Assistance Listing No. 84.411A Criteria: 2 CFR 200.332 notes, “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; …” Condition: For both subawards selected for testing, the identification of the contact information for the awarding agency was incorrect. The contact information was Education Analytics, Inc., the Organization’s grantor, but should have been Future Forward, Inc. Further, one of the two subawards selected for testing had information missing from the subaward including all requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award. We consider this condition to be an instance of noncompliance relating to the Subrecipient Monitoring compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: Without communication of the required information, subrecipients may overspend award amounts or incur unallowable expenses towards the grant as well as report the incorrect grantor on their schedule of expenditures of federal awards. Recommendation: We recommend the Organization evaluates policies and procedures to ensure all required information is communicated with the subrecipient. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward; and that subaward performance goals are achieved." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward; and that subaward performance goals are achieved." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward; and that subaward performance goals are achieved." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward; and that subaward performance goals are achieved." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward; and that subaward performance goals are achieved." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
Subrecipient Monitoring Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLT0790; 2021 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.332 includes requirements such as evaluating the subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The City did not have documentation of risk assessment procedures performed for two of the four subrecipients tested. Questioned Costs: None. Context: The City of Minneapolis has documented the subaward and subrecipient procedures that its staff are expected to follow. These procedures include the completion of a pre-award risk assessment form and for the form to be maintained in the contract file of the subrecipient. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City is not in compliance with federal regulations. Cause: City staff were not aware of the requirement to perform pre-award risk assessments with subrecipients. Recommendation: We recommend the City ensure that the City’s employees follow its procedures for completing risk assessments when contracting with subrecipients. View of Responsible Official: Concur
Criteria: 2 CFR 200.332 establishes requirements for pass-through entities. Included in these requirements is to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The City did have procedures in place to monitor allowable costs and activities of its subrecipients. However, while conducting a review of expenditures through the monitoring of the Appalachia Community Grant (ACG), the Ohio Department of Development (ODOD), noted that a subrecipient of the City had made unallowable expenditures for the grant. This demonstrates a control weakness in the subrecipient monitoring controls conducted by the City. Context: The City, ODOD, and the subrecipient are working on a way to recover any questioned costs associated with this and these do not represent questioned costs of the City. Effect: There is a significant deficiency in the subrecipient monitoring controls of the City that could allow future unallowable costs or activities at subrecipients, if not improved. Recommendation: We recommend that the City implement stronger monitoring controls including vendor verification and review of invoices for the draw down requests that they receive from their subrecipients.
FINDING 2024-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Subrecipient Monitoring Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2024 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 HANCOCK COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The County received an allocation of the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) from the U.S. Department of the Treasury to support its response and recovery from the novel coronavirus. A portion of the County's allocation was then used to subaward funds to another entity (i.e., the subrecipient) to carry out an eligible use. The subaward was provided to the subrecipient via two different subaward agreements. Both subaward agreements were selected for testing. The County, as the pass-through entity, is to clearly identify the subaward and the terms and conditions of the award in the agreement with the subrecipient. During review of the two subaward agreements, it was determined that the Assistance Listings Number (ALN) and Federal Award Identification Number (FAIN) were not included as required. Additionally, the County as the pass-through entity, is to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and terms and conditions of the subaward and that performance goals are achieved. Part of the monitoring requirements include verifying the subrecipient received an audit as required so as to be able to issue management decisions on any findings, as applicable. The County did not have a process in place to obtain and review audits received by the subrecipient. Therefore, the County would not have been able to issue management decisions or ensure timely and appropriate action by the subrecipient. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: "(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.332 states in part: "All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); INDIANA STATE BOARD OF ACCOUNTS 14 HANCOCK COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date . . . of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the passthrough entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R & D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used charged) per § 200.414. . . . (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations." Cause The County did not have adequate processes or procedures in place to ensure all of the proper information about the grant was provided to the subrecipient and all required monitoring activities were being conducted. Effect Not providing award identification information to subrecipients could result in the subrecipient not properly reporting the grant on their Schedule of Expenditures of Federal Awards. Furthermore, due to the absence of policies and procedures to monitor the activities of subrecipients, subrecipients could be spending federal funds for unauthorized purposes without the County's knowledge. As such, the County cannot ensure proper accountability and compliance with the program requirements. INDIANA STATE BOARD OF ACCOUNTS 15 HANCOCK COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County strengthen its system of internal controls to ensure that the County verifies that all subrecipients of federal awards receive an audit and that the County receives and reviews any audit reports of the subrecipients. Additionally, we recommended that the County strengthen its system of internal controls to ensure that subaward agreements include all required information that should be known to the subrecipient. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria or specific requirement: Per 2 CFR 200.303(a), the County must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the ”Standards for Internal Control in the Federal Government” issued by the Comptroller General of the Untied States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Under Uniform Grant Guidance, the County must: • Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain required information including but not limited to: Federal and subaward information, indirect cost rate, and the subrecipient’s unique entity identifier (UEI). (2 CFR 200.332 (b)) • Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. (2 CFR 200.332 (c)) • Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. (2 CFR 200.332 (e)) • Verify that a subrecipient is audited as required by 2 CFR 200.501. (2 CFR 200.332 (g))Condition: Subaward agreement was expired and did not include all required information, nor did the subrecipient have the required UEI. Subaward requirements were not communicated to the subrecipient; therefore, monitoring activities were not effective. Documentation of subrecipient risk assessment or audit verification not available for audit.Questioned Costs: None noted.Context: Audit procedures included testing of the one subrecipient who received a subaward during the year. There were no other subrecipients.Cause: The County’s procedures were not sufficient to ensure the subawards were issued or monitored in compliance with Federal requirements. Internal controls did not prevent or detect the errors.Effect: Failure to properly document required contract information, perform the necessary risk assessments, and document the review of the subrecipient’s single audit may result in noncompliance with grant terms and conditions. Subrecipients may have incomplete Schedules of Expenditures of Federal Awards, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2024-004: 10. 761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and Training - Material Weakness Compliance Requirement: Subrecipient Monitoring Criteria: Per Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Subpart D, section 200.332, the non-Federal entity must determine the subrecipient is not excluded or debarred or otherwise excluded from receiving Federal funds, as well as develop written subrecipient monitoring policies and procedures. Condition: During our testing of internal controls over compliance related to subrecipient monitoring, we identified EWB-USA did not have written subrecipient monitoring policies or procedures in place, nor determine that the subrecipient was not suspended or debarred or otherwise excluded from receiving Federal funds. Additionally, EWB-USA did not obtain a copy of the subrecipient's Uniform Guidance compliance audit. Questioned Costs: None. Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable federal requirements. Effect: EWB-USA was not in compliance with the subrecipient monitoring provisions as prescribed in the Uniform Guidance. Recommendation: We recommend that EWB-USA adopt formal, written subrecipient monitoring policies and procedures the comply with the Uniform Guidance. Response: 1. Develop a policy for subrecipient monitoring, and implement procedures to oversee the programmatic and financial activities of subrecipients and ensure compliance with regulations. 2. Develop a standardized checklist to guide the monitoring of subrecipients. 3. Provide training to relevant staff on the new procedures for subrecipient monitoring and the importance of compliance with federal regulations.
Finding 2024-004: 10. 761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and Training - Material Weakness Compliance Requirement: Subrecipient Monitoring Criteria: Per Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Subpart D, section 200.332, the non-Federal entity must determine the subrecipient is not excluded or debarred or otherwise excluded from receiving Federal funds, as well as develop written subrecipient monitoring policies and procedures. Condition: During our testing of internal controls over compliance related to subrecipient monitoring, we identified EWB-USA did not have written subrecipient monitoring policies or procedures in place, nor determine that the subrecipient was not suspended or debarred or otherwise excluded from receiving Federal funds. Additionally, EWB-USA did not obtain a copy of the subrecipient's Uniform Guidance compliance audit. Questioned Costs: None. Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable federal requirements. Effect: EWB-USA was not in compliance with the subrecipient monitoring provisions as prescribed in the Uniform Guidance. Recommendation: We recommend that EWB-USA adopt formal, written subrecipient monitoring policies and procedures the comply with the Uniform Guidance. Response: 1. Develop a policy for subrecipient monitoring, and implement procedures to oversee the programmatic and financial activities of subrecipients and ensure compliance with regulations. 2. Develop a standardized checklist to guide the monitoring of subrecipients. 3. Provide training to relevant staff on the new procedures for subrecipient monitoring and the importance of compliance with federal regulations.
2024-001: Internal Control over Compliance with Subrecipient Monitoring and Noncompliance with Subrecipient Monitoring U.S. Department of Health and Human Services; Passed through the State of Tennessee Department of Health: ALN #93.558 Temporary Assistance for Needy Families Federal Award Identification: 68080 Grant Year: 10/1/2020-9/30/2024 Criteria: 2 CFR section 200.332(d) states: Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200-521. Condition and context: The Organization typically requests and reviews subrecipient financial statement audits on an annual basis with annual renewals of contracts. The Temporary Assistance for Needy Families Grant has a three-year grant period. Since subrecipients weren't required to have annual renewals, the Organization did not request or review the annual financial statement audits of subrecipients of this grant. Therefore, the Organization did not comply with the monitoring required by 2CFR section 200.332(d). Cause: The Organization’s internal controls over subrecipient monitoring were not sufficiently designed and implemented to ensure that applicable audits from subrecipients were obtained and reviewed annually. Effect or potential effect: Procedures required by 2 CFR section 200.332(d) related to reviewing financial reports of the subrecipient and following-up on deficiencies pertaining to the Federal award could not completed. The Uniform Guidance audit could have noted findings related to compliance with the spending of the federal assistance that would have been unknown to the Organization. Recommendation: We recommend that the Organization track all subrecipient with federal assistance and establish a process to ensure the financial statement and Uniform Guidance audits are obtained timely and monitoring procedures required by 2 CFR section 200.332(d) are completed. Views of responsible officials: Management acknowledge this finding and will address remediation in the accompanying corrective action plan in Appendix A
Federal Agency: United States Department of Commerce Federal Program Name: Office for Coastal Management Assistance Listing Number: 11.473 Federal Award Identification Year: 2020 Pass-Through Agency: National Fish and Wildlife Grant Agreement Award Period: 9/1/20-08/02/24 Compliance Requirement Affected: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted. Context: A nonstatistical sample of 2 out of 4 subrecipients were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over CFSC’s subrecipients. Effect: CFSC did not perform the following, which increases the risk of noncompliance: -Required risk assessments for the subrecipients, -Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any. Cause: CFSC’s procedures did not consistently ensure that the required risk assessments were performed. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above. Management’s Views: See separate corrective action plan.
Criteria: Per 2 CFR 200.332, Mesa County is responsible for informing subrecipients of the Federal award identifiers including but not limited to award date, period of performance and Federal awarding agency and Assistance Listing Number and title. Mesa County is required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. In addition, the County should also verify that the subrecipient is audited as required by Subpart F - Audit Requirement under the Uniform Guidance. The monitoring policy should include an initial valuation of risk of noncompliance to determine the appropriate level of monitoring required related to the subaward as well as appropriate awarding documentation. Condition: During our testing, we evaluated the procedures for evaluating subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. We noted the following: • For two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient’s risk of noncompliance was not documented. Cause: The County did not adhere to their established policies and procedures relating to risk assessment when a subrecipient contract is awarded. Effect: The County’s policies were not consistently followed requiring compliance with the Subrecipient monitoring requirements in 2 CFR 200.332. Additionally, the County’s control policies were not consistently followed. Questioned Costs: None to report. Context/Sampling: The population of two (2) subrecipients were selected for subrecipient monitoring testing for the direct award from the US Department of Treasury. The total population across the program, including sub-awards from the State of Colorado was 2 subrecipients. Repeat Finding from Prior Years: Yes. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Agree
Significant deficiency in internal controls over subrecipient monitoring. • Program Title: Substance Abuse Block Grants • Assistance Listing Number: 93.959 • Federal award identification number: B08TI085843 • Federal Agency: Department of Health and Human Services • Pass-through Entity: Washington State Health Care Authority Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.332 requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward. Condition/Context Washington Association of Sheriffs & Police Chiefs (the Association) passes substantially all federal funding through to subrecipients. During testing it was identified that, although the Association satisfied all ongoing monitoring requirements, on the coversheet of all subrecipient contracts in place during the year, a box indicating that the third party was not a subrecipient was incorrectly checked. This error by default incorrectly communicated to their subrecipients that they were contractors. Cause Washington Association of Sheriffs & Police Chiefs’ internal controls related to the review of subrecipient contracts were not functioning properly causing the pervasive error to be overlooked. Effect or potential effect Subrecipients were not clearly communicated their roles. Questioned costs N/A Repeat audit finding No Recommendation We recommend that Washington Association of Sheriffs & Police Chiefs ensure there is a proper understanding of the nature of a subrecipient vs a contractor, and that they ensure that this determination is being reviewed, and clearly communicated in underlying agreements, as part of their internal control processes Views of responsible officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report
Criteria: In accordance with 2 CFR 200.332(d), recipients of federal awards who pass funds to subrecipients are required to monitor the activities of subrecipients to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Required monitoring includes reviewing financial and performance reports, following up on deficiencies, and ensuring timely corrective action is taken. Condition: During the year ended December 31, 2024, FFT passed CSLFRF funds to one subrecipient. FFT did not perform any documented monitoring activities over this subrecipient. Specifically, FFT did not obtain or review financial and performance reports, nor did it conduct site visits, desk reviews, or other monitoring procedures required to ensure compliance with federal regulations. Cause: FFT did not establish formalized subrecipient monitoring procedures for CSLFRF funds, due in part to a misunderstanding of its responsibilities as a pass-through entity and the federal compliance requirements related to subrecipient oversight. Effect: As a result of inadequate subrecipient monitoring, there is an increased risk that subrecipients may have expended federal funds on unallowable costs or failed to comply with CSLFRF program requirements. This deficiency exposes FFT to potential repayment of funds and reputational risk if noncompliance is identified at the subrecipient level. Questioned Cost: No specific questioned costs were identified; however, the total amount of CSLFRF funds passed through to the subrecipients without adequate monitoring was $353,050, which is considered to be at risk of noncompliance. Recommendation: We recommend that FFT establish and implement formal subrecipient monitoring procedures to ensure compliance with 2 CFR 200.332(d). This should include, developing a documented monitoring plan for CSLFRF subrecipients, obtaining and reviewing periodic financial and performance reports from subrecipients, performing documented follow-up on any deficiencies noted, and providing training to responsible staff regarding subrecipient monitoring requirements. Views of Responsible Officials: See 2024 Corrective Action Plan.
2024-002 Finding – Federal Award Type: Subrecipient Monitoring – Non-Compliance and Significant Deficiency in Internal Control Over Compliance. AL Number: 10.163 Market Protection and PromotionCriteria / Requirement: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In accordance with 2 CFR section 200.332, a pass-through entity must clearly identify to the subrecipient the award as a subaward by providing the required federal information related to the award, all requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the provisions of contracts and grants agreements. The pass-through entity must evaluate risk of non-compliance of each subrecipient, monitoring the subrecipient and ensuring accountability of for-profit subrecipients. Condition / Context: Oregon Tilth passed through $1,593,444 in funding to subrecipients under Assistance Listing 10.163. During our audit, we noted that Oregon Tilth did have documented written procedures or controls in place to ensure compliance with the U.S. Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. It was noted that within subaward contracts, required federal contract information was provided. Further, subrecipients are being evaluated for risk of non-compliance, prior to engaging in a subcontract. While monitoring has improved, as Oregon Tilth is having regular meetings to ensure tasks are being completed timely and providing technical assistance when needed, it was noted that in the sample of five subrecipients, three subrecipient was subject to 2 CFR Subpart F and the audit for this entity was not obtained. Per 2 CFR 200.332(d)(2) & (3), an entity must ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, highlighting the status of action planned or taken to address Single Audit Finding related to the subaward. They must also issue a management decision for applicable audit findings. Further, per 2 CFR 200.332(g), pass-through entities must verify that a subrecipient is audited as required by 2 CFR 200 subpart F. Oregon Tilth did have the subrecipient answer a questionnaire that included a question asking if the subrecipient was subject to 2 CFR 200 subpart F, however they did not obtain the audit or verify in any other way that the client was audited as required by 2 CFR 200 subpart F. Cause: Procedures were in place to ensure that Oregon Tilth is maintaining proper subrecipient monitoring for each federal subrecipient, however the procedures were not fully compliant with 2 CFR 200.332. Effect: Failure to maintain sufficient subrecipient monitoring may result in the wrongful use of federal funds and non‐compliance with the provisions of applicable requirements of the federal award. Questioned Costs: None. Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Management’s Response: Management concurs with the finding and will implement effective internal controls to ensure that subrecipient monitoring is properly done and documented appropriately.
Finding 2024-004 – Subrecipient Monitoring U.S. Department of Commerce Economic Development Cluster ALN 11.307 Grantor Number 01-79-15312 Condition: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. Specifically, there is no documented review of subrecipient financial or performance reports, no formal risk assessments conducted prior to disbursement of funds, and no site visits or other monitoring activities to ensure compliance with award terms and federal regulations. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Criteria of Specific Requirement: Pass-through entities are required to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients are notified of their requirement to receive an audit and take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients and 2 CFR section 200.332(a) required pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN and amount that was paid during the year. Questioned Costs: Unknown Cause: The Organization does not have procedures in place to document the assessment of risk for subrecipients. In addition, the Organization does not have procedures in place to adequately review all subrecipient audits or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is a repeat finding. Recommendation: The Organization should review all contract documents for conditions and terms, and based upon that review, implement procedures to ensure subrecipient monitoring includes proper risk assessment and monitoring of single audit compliance, along with any other grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.
Finding 2024-002 Agency: Department of Labor Program: Apprenticeship State Funds (AL No. 17.285) Material Weakness over Subrecipient Monitoring Repeat Finding: No Condition: For all subrecipients of AACC, there was no supporting documentation to show that a risk assessment was performed by the pass-through entity before awarding funds to each subrecipient. Additionally, for monitoring procedures performed AACC used general subrecipient monitoring forms which were all signed in March 2025 which is after the annual monitoring period ending December 31, 2024. The monitoring forms did not include information related to missing support for various subrecipient invoices as noted in finding 2024-001. Additionally, there were no follow-up procedures documented on the forms to ensure corrective action took place. Criteria: As provided in 2 CFR section 200.332: Requirements for pass-through entities, a pass-through entity must evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. Cause: AACC does not have a policy in place to properly document risk assessment of subrecipients before awarding funds to them. AACC does not have a policy in place to ensure all necessary monitoring procedures performed based on its risk assessment are properly documented in a timely manner. Effect: AACC was not in compliance with the Subrecipient Monitoring requirements in accordance with Uniform Guidance. Questioned Costs: Unknown Recommendation: We recommend AACC implements a policy to properly document their assessment of their subrecipients fraud risk and risk of noncompliance to then conclude on satisfactory monitoring procedures. We recommend AACC implements a policy to properly document all necessary monitoring procedures in a timely manner. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report.